A Major Search and Seizure Case Is Coming to the Supreme Court

Expanding the community-caretaking doctrine beyond Cady’s bounds, however, is more controversial. Cars and other motor vehicles, which did not exist when the Fourth Amendment was drafted in 1791, generally receive less protection from warrantless searches under the court’s precedents than, say, a residence. For that exact reason, the court recently declined to extend the doctrine to a person’s home.

In the 2021 case Caniglia v. Strom, a man sued police officers who had entered his home as part of a wellness check after he allegedly placed a handgun on a table and told his wife to “shoot now and get it over with” during an argument. The officers invoked the community-caretaker doctrine, and the First Circuit Court of Appeals agreed. Justice Clarence Thomas, writing for a unanimous court, held that the appeals court’s decision went too far.

“Neither the holding nor logic of Cady justified that approach,” he wrote. “True, Cady also involved a warrantless search for a firearm. But the location of that search was an impounded vehicle—not a home—‘a constitutional difference’ that the opinion repeatedly stressed. In fact, Cady expressly contrasted its treatment of a vehicle already under police control with a search of a car ‘parked adjacent to the dwelling place of the owner.’”